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STUBBS v. COMMISSIONER OF I.R.S.

No. 85-8447 Non-Argument Calendar.

797 F.2d 936 (1986)

Charles H. STUBBS, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

August 25, 1986.

Attorney(s) appearing for the Case

Glenn L. Archer, Jr., U.S. Dept. of Justice, Tax Div., Michael L. Paup, Robert S. Pomerance, Douglas G. Coulter, Washington, D.C., for respondent-appellee.

Before GODBOLD, Chief Judge, VANCE and JOHNSON, Circuit Judges.

PER CURIAM:

Stubbs appeals the tax court's grant of summary judgment in favor of the Commissioner of Internal Revenue Service ("Commissioner") on Stubbs' liability for tax deficiencies and penalties for the years 1976 through 1980. The tax court may grant summary judgment if "there is no genuine issue as to any material fact and ... a decision may be rendered as a matter of law." Tax Court Rule 121(b). Summary judgment may be based on "the pleadings, ... admissions...

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